Leigh Sayliss (Memery Crystal) considers the effects that changes in one linked transaction can have on others.
SDLT is a progressive tax: the more that is paid for a chargeable interest the higher the effective percentage rate of SDLT will be. Given that SDLT was structured so as to minimise the risk of tax avoidance it is not surprising that the legislation uses ‘linked transactions’ to stop purchasers from fragmenting purchases into multiple transactions and use the lower rates of SDLT more than once.
Where a purchaser (or anyone connected with the purchaser) acquires more than one chargeable interest from the same vendor (or anyone connected with the vendor) as part of a single scheme arrangement or series of transactions the transactions will be ‘linked transactions’ (FA 2003 s 108) and the total amount of SDLT will be calculated as if there had been a single...
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Leigh Sayliss (Memery Crystal) considers the effects that changes in one linked transaction can have on others.
SDLT is a progressive tax: the more that is paid for a chargeable interest the higher the effective percentage rate of SDLT will be. Given that SDLT was structured so as to minimise the risk of tax avoidance it is not surprising that the legislation uses ‘linked transactions’ to stop purchasers from fragmenting purchases into multiple transactions and use the lower rates of SDLT more than once.
Where a purchaser (or anyone connected with the purchaser) acquires more than one chargeable interest from the same vendor (or anyone connected with the vendor) as part of a single scheme arrangement or series of transactions the transactions will be ‘linked transactions’ (FA 2003 s 108) and the total amount of SDLT will be calculated as if there had been a single...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
